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OCC Outlines 2022 Bank Supervision Operating Plan's picture
Commentary by Daniel Meade

The OCC outlined its bank supervision operating plan for fiscal year 2022. The plan serves as guidance to staff members in their supervision of banking entities.

Among other things, the plan described the following priorities for examiners:

  • "strategic and operational planning," particularly as to capital, credit loss allowances, net interest margins and earnings (the plan also describes this as "guarding against complacency");

  • allowances for loan and lease losses, and allowances for credit losses;

  • cybersecurity risk management and operational resilience;

  • third-party relationship management and oversight;

  • Bank Secrecy Act/AML and Community Reinvestment Act compliance;

  • fair lending and interest rate risk management;

  • LIBOR transition planning;

  • payment systems products and services, and related risk management;

  • FinTech and cryptocurrency activities and related governance; and

  • climate-related risk management.

The OCC noted that it will provide regular updates to the supervisory focus in its "Semiannual Risk Perspective."


The target audience for the operating plan is the examiner staff of the OCC, but it clearly gives insights that are valuable for national banks to be prepared for this year. The plan is consistent with what Acting Comptroller Michael J. Hsu has been saying in speeches and testimony.

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